Practice question
A taxpayer omitted suspension relief from its petition but later files a properly supported separate motion while the case remains pending. Is the motion barred solely because it was not attached to the petition?
- No; Rule10 allows a separate motion at any stage of the proceedings
- Yes, omission from the petition permanently waives it
- Yes, only the BIR may ever seek suspension
- Yes, evidence cannot be filed later
- Yes, the court loses every interim power after summons
Legal references
- Revised CTA Rules: https://lawphil.net/courts/supreme/am/am_05_11_07_cta_2005.html Rule10 Sections3–7.
- Spouses Pacquiao v CTA GR213394 April6,2016 MAIN: https://lawphil.net/judjuris/juri2016/apr2016/gr_213394_2016.html MAIN evidence-dependent determination.
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